The EU Omnibus has left the garage ‒ what do you do now?

On 26 February 2025, the European Commission published the anticipated Omnibus proposal, which many companies have been looking forward to with both nervousness and a certain relief. The proposal, which is now familiar to most people working with ESG, aims to reduce the extensive reporting burden for companies.

The Omnibus proposal seeks to reduce both the scope of companies affected and the actual reporting requirements for CSRD, EU Taxonomy and CSDDD (as well as CBAM). This represents a significant change from the original course, and many companies now face a dilemma: Should they continue the work they have begun, or should they take a breath and wait for the dust to settle after the bus?

The proposal must, of course, go through the political mill in the EU and in countries that have already implemented the directives/regulation. It may take time before it is approved and implemented in the member states. The European Council has just approved the proposal for expedited approval of the "stop the clock" element – precisely to give companies that have not yet had to report the necessary peace of mind right now, until there is legal clarity regarding the other proposals.

The question 'CSRD or not CSRD?' is now more relevant than ever. But regardless of reporting scope, the framework has significant value as an effective management tool. The double materiality assessment (DMA) – the foundation of sustainability reporting – is a complex concept that requires investment but provides substantial returns by very concretely linking sustainability to business strategy.

We encourage a risk-based approach to processes and data points. Going forward, the focus can shift from compliance to monitoring initiatives and driving real change. It is no longer just about reporting – it is about creating value for the company and for the world around us.

The first step is to pause and reflect on the work and preparations that have already been carried out. Have you already invested significant resources in CSRD preparations? Or are you just getting started? Your starting point is crucial for how you should act now.

Be aware of your strategic priorities, and plan your efforts accordingly.

You will most likely not come within the scope of CSRD etc. Consider pausing your CSRD preparations, but still conduct a DMA to ensure understanding of your impacts. Consider VSME reporting for B2B information and take into account requirements from key stakeholders such as customers and banks.

Reflect on your strategic goals and the commitments you have joined, e.g., SBTi, UNGC, CDP, EcoVadis etc., which need to be communicated and reported independently of CSRD. Also consider whether the company may be included in the future due to growth plans, and what the practice for sustainability reporting in your industry is, and how you see it developing.

There is a possibility that you will not come within the scope of CSRD, but it is still unclear whether the threshold will be 1,000 employees, or if it will be lower, e.g., 750.

The situation is unclear and depends on political negotiations. Therefore, it is best to continue the work, but keep focus on the most essential elements. Here it is worth considering DMA and due diligence procedures for your most significant direct suppliers (Tier 1) as well as including financial risks in your risk assessment and business model. Also, keep an eye on the remaining effects of CSDDD.

An important, concrete action is to align top management's expectations and, based on these, implement a well-thought-out, phased approach that fits your situation. Additionally, consider how you can best use the extra time to create robust and efficient data management and reporting processes.

You will still be within the scope of CSRD when it is phased in. Therefore, continue your CSRD work.

First and foremost, you need to close the quantitative data gaps from your first reporting (if you reported in 2024). After that, it makes sense to streamline and digitize processes, develop a climate transition plan, address risks and opportunities and additionally begin to prepare for CSDDD and taxonomy reporting, if you have not already done so the first time.

If you have already reported for 2024, it is a good idea to reflect on what you have learned in the first year of CSRD reporting. Consider which strategic elements in your CSRD reporting are the most important, and whether they are being utilised in the best possible way, and identify the areas where you can advantageously strengthen the robustness of the company's sustainability work and reporting – or simplify processes and procedures in year two.

Regardless of company size, it is crucial to find the right balance between taking advantage of the potential relief and maintaining momentum in sustainability work.

Companies that use this period strategically to focus their efforts will stand stronger when the final requirements are in place.

Remember that sustainability remains a competitive parameter, and customers, investors and employees continue to expect action – regardless of how legislation develops.

Basico has always had a practical approach to ESG reporting and especially CSRD, so we welcome the simplification of reporting requirements. All things considered, it is more exciting and professionally challenging to talk about creating value from ESG rather than compliance.

Many companies are now pausing and may also be putting a planned expansion or upskilling of the ESG team on hold. In this transition period, it may therefore be advantageous to seek external help to navigate the changed requirements.

We can help companies with:

• Interim ESG assistance, such as controller, ESG manager or extra resource that can support you in the transition phase
• Ongoing sparring and advice as needed on both strategic and practical aspects
• Development and implementation of business-oriented ESG reporting that creates value
• Design and implementation of cost-effective and reliable ESG processes
• Help with selection and acquisition of an ESG platform that fits your needs
• Implementation of IT support for ESG work, giving you a smooth process.

You are very welcome to contact us for a non-binding dialogue about how we can help your specific company navigate the changed sustainability reporting requirements and find the right balance between value creation, compliance and effort.